As the FMTA, we support immediate changes to ensure that dwelling room tenants displaced by redevelopment have access to replacement or alternate housing at rents similar to what they were paying. Dwelling room tenants are among the City’s most vulnerable residents and we at the FMTA have seen firsthand the effects of this lack of regulation on the lives of City residents. While the proposal by Councillor Saxe to further amend Official Plan Amendment (OPA) 453 is a step in the right direction, we urge the City of Toronto to further examine the loopholes of the current By-Law through the following recommendations:

• Relocation & Assistance to All Dwelling Room Tenants: City Planning should update its unofficial tenant relocation and assistance policies to require developers to provide ALL displaced dwelling room tenants with replacement units or comparable housing at similar rents retroactive to implementation of the Multi-Tenant Housing (MTH) By-Law. This change would protect tenants, including those at 262–266 St. George Street, and prevent homelessness in vulnerable communities.
• Protecting Affordable Housing in Current Developments: City Planning must ensure dwellings slated for redevelopment are properly defined under current City of Toronto By-Laws to prioritize tenant protections. Housing should be classified in a way that maximizes safeguards for tenants and preserves affordable rental housing. 
• Improve Tracking and Reporting Outcomes: The City should enhance its monitoring and reporting on rental replacement policies by:
  • Requiring licensed landlords to submit annual rent rolls to track affordability changes.
  • Publicly report on replacement unit details, including affordability and tenant outcomes.
  • Tracking tenant outcomes, including whether displaced tenants return to redeveloped buildings, why some do not, and the overall impact of displacement. 

Background

The City of Toronto’s 2024 Multi-Tenant Housing By-Law has helped dwelling room tenants fight back against predatory landlords, but more needs to be done to protect tenants and their access to affordable housing. Councillor Diane Saxe is proposing an amendment to OPA 453 to address the situation at 262–266 St. George Street, where 39 occupied dwelling rooms would be replaced by just 12 bachelor and a one-bedroom unit spread over an allegedly equivalent gross floor space in a new 86-unit building. While the new building would include 30 bachelor units, only 12 would be at comparable rents—leaving most tenants unable to afford them.

Councillor Saxe’s motion calls for two key reports:

1. By the end of 2025, the Chief Planner must review whether OPA 453 should be updated to force developers who tear down six or more dwelling rooms to replace them with affordable units for all displaced tenants.
2. By early 2026, the Chief Planner must also review whether demolishing 10 or more rental bedrooms should provide the same tenant protections as demolishing six or more full dwelling units.

While this proposal is a positive step, these reports do not go far enough to address the challenges faced by dwelling tenants as any exception to tenant rights leave them at further risk of homelessness. At FMTA, we’ve already seen how loopholes in provincial tenancy laws and the City’s by-laws leave vulnerable tenants unprotected. Stronger action is needed to close these gaps and keep tenants housed.

Loopholes and Exceptions

The challenges faced by tenants at 262–266 St. George Street highlights gaps in provincial laws and municipal bylaws that the City must address. In this particular case, misclassification of these rental units by the landlord exempts them from replacement requirements and tenant protections. Through proper classification under the MTH licensing framework, the 5-and 6-room units on St. George would qualify as multi-tenant housing, offering replacement requirements and tenant protections. Sadly, this is the tip of the iceberg when it comes to the many challenges tenants face on a daily basis.

Through our work educating MTH residents about their rights under Toronto’s new bylaw, FMTA has identified numerous loopholes in enforcement.

One of the main shortfalls of the MTH By-Law is that it focuses primarily on enforcing building standards and ensuring landlord compliance, but fails to adequately examine tenant outcomes or provide necessary support for those displaced as a result of enforcement actions. A clear example of this shortcoming is seen at 30 Charles Street East, where units were illegally converted into multi-tenant housing, violating city regulations. 

While the City has the authority to enforce bylaws and hold landlords accountable, the by-law does not address the precarious situations faced by tenants who may be evicted due to these enforcement actions or landlords exploiting regulatory loopholes. Tenants in such scenarios often find themselves without adequate protections, resources, or alternative housing options, highlighting a significant gap in the by-law’s framework that prioritizes compliance over the well-being and stability of vulnerable renters. This oversight underscores the need for a more tenant-centered approach that considers the human impact of housing enforcement and provides robust support systems for those affected.

Landlords are also increasingly exploiting loopholes in the provincial Residential Tenancies Act (RTA), particularly the provision allowing landlords to claim they are “living on the premises,” to strip tenants of their rights by reclassifying them as roommates rather than tenants. This legal distinction denies these individuals the protections afforded under the RTA, leaving them vulnerable to arbitrary evictions and exploitation. In some cases, occupants acting as “agents of the landlord” have collected rent on behalf of the landlord, while others have used force or coercion to illegally evict tenants or abruptly terminate subleases, leaving tenants with nowhere to go. Regardless of the legality of these actions, the consequences for tenants are devastating, particularly for those in multi-tenant housing, which often serves as a last resort before homelessness. 

As advocacy organizations for the unhoused have repeatedly emphasized, shelters are already overcapacity and unable to meet the growing demand. To address this crisis, the City must prioritize preventing homelessness by closing these loopholes and implementing stronger tenant protections, ensuring that vulnerable individuals are not pushed further into housing insecurity and onto the streets.

As such, the city should do everything in its power to address these loopholes and exceptions by invoking the recommendations outlined above.

Conclusion

In conclusion, the FMTA strongly advocates for immediate and comprehensive changes to protect dwelling room tenants from displacement and homelessness caused by redevelopment. While Councillor Saxe’s proposed amendments to OPA 453 are a positive step, it falls short of addressing the systemic loopholes in both provincial and municipal housing laws that leave vulnerable tenants exposed to exploitation and housing insecurity. 

The City must prioritize tenant protections by ensuring proper classification of dwelling rooms, enforcing replacement unit requirements, and providing robust relocation assistance to all displaced tenants. Additionally, improved tracking and reporting mechanisms are essential to hold developers accountable and ensure transparency in tenant outcomes. 

The current Multi-Tenant Housing By-Law, while a step forward, must evolve to address the human impact of enforcement actions and close the gaps that allow landlords to circumvent tenant protections. By adopting the recommendations outlined above, the City of Toronto can take meaningful action to prevent homelessness, preserve affordable housing, and safeguard the rights of its most vulnerable residents. The time to act is now—before more tenants are pushed into homelessness due to inadequate policies and enforcement.

Federation of Metro Tenants’ Associations

(416) 646-1772

PO Box 73102 Wood St.
Toronto, ON, M4Y 2W5 

[email protected]

www.torontotenants.org